1

December, 17 2015

Attn: U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE., Washington, DC 20590

RE: MICHAEL YOUNG REQUEST S AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJ I
Phantom 3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PU BLIC LAW 112

- 95)

Michael Young

2021 West 73 rd Street
Tulsa Oklahoma 74132

918

- 691

- 3241

young. mike1954@gmail.com2 

## TABLE OF CONTENTS
Page

GLOSSARY OF ABBREVIATIONS...............................................................................

............................... ....3

SUMMARY......................................................................................................................

. ....................... ....4

INTRODUCTION AND INTERESTS OF PETITIONER.......................................

................................... .............4

BACKGROUND.....................................................................................................

.............. . ........... ..............4

BASIS FOR PETITION...................................................................................

......... ........................... .............5

NAME AND ADDRESS OF PETITIONER..............................................

..................... ........ ........... ...................6

THE SPECIFIC SECTI ONS OF 14 C.F.R. FROM WHICH MICHAEL YOUNG SEEK S EXEMPTION

.... ...................6

THE EXTENT OF RELIEF MICHAEL YOUNG SEEKS AND THE REASON MICHAEL YOUNG SEEKS THE RELIEF

................................................................................................................................................................................ ....8

THE REASONS WHY GRANTING MICHAEL YOUNG ’S REQUEST WOULD BE IN THE PUBLIC INTEREST .......10

THE REASONS WH Y GRANTING THE EXEMPTION TO MICHAEL YOUNG WOULD NOT ADVERSELY AFFECT
SAFETY..........................

............................................ ............. ................................ ..................... . . ..............11

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.......

.......................................... .. . .......... 19

ANY ADDITIONAL INFORMATION, VIEWS, OR ARG UMENTS AVAILABLE TO SUP PORT MICHAEL YOUNG ’S
REQUEST...........................

....... .................................................................................. ................ ...... . ..........20

CONCLUSION...................................

........................ .......................................................................... . ........203 

## GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS Natio nal Airspace System

NOTAM Notice to Airman
PIC Pilot In Command
Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft Sys tem
VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing4 

## SUMMARY
Michael Young seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (DJI Phantom 3) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Michael Young to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, residential and commercial real estate, civil landscapes and events over certain areas of the United States.



## INTROD UCTION AND INTERESTS OF THE PETITIONER
Michael Young has been a Private Pilot since 10/22/1990 and Instrument Rated Private Pilot since 4/2/1992 and also has expertise and knowledge in video and m ultimedia using advanced technologies
and solutions. Michae l Young has had over 97 hours o f flight training, completed over 800 hours of total flight time with over 250 hours in instrument conditions with a perfect safety record. Michael Young has safely flown small RC electric quad copters recreationally for appr oximately 2 years without incident. The objective of Michael Young and the Unmanned Aircraft System (DJI Phantom 3) aerial operation is to provide an affordable, high

- quality production syste m for a variety of commercial, public, and residential uses, spe cifically targeting :

• Construction sites before and after • Appraisals
• Real

- estate marketing • Economic development
• Civic landmarks • Special event coverage
• Private training



## BACKGROUND
Unmanned Aircraft Systems: DJI Phantom 3, UAS
Michael Young seeks an exemption to operate DJI Phantom 3 system s for compensation or hire within the NAS. The DJI Phantom 3 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart pho ne systems. The DJI Phantom 3 has a maximum gross weight of approximately 2.8 lb. while having a diagonal dimension of 23.2”, a maximum speed of approximately 16. 4 fps and a maximum flying height of 400'. The DJI Phantom 3 is equipped with four main rotors ; driven by Lithium Polymer ba ttery powered electric motors. The DJI
Phant om 3 that will be operated by Michael Young will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and m arked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.5 

## BASIS FOR PETITION

Petitioner, Michael Young , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform A ct of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the DJI Phantom 3, UAS in the National Airspace System (NAS), and for an exemption from the requirements of

14 C .F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Mich ael Young ’s operation of DJI Phantom 3 UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, Michael Young requests relief from Sections 91.4 05(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft
with an airworthiness certificate. Michael Young submits that the requested relief is proper since an equ ivalent level of safety will be
ensured. Michael Young will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating document s ( DJI Phantom 3 Instru ction Manual). Furthermore, Michael Young will document and maintain all maintenance records for the DJI Phantom 3 UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and
limitations: Pilot in command , is requested by Michael Young to the extent necessary to allow a Pilot in Command (PIC) holding a sport pilot or higher level certificate, as well as a valid driver’s license , that the PIC is able to safely operate the DJI Ph antom UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles
and structures. Michael Young seeks relief from Section 91.7(a), entitled Civil aircraft a irworthiness , because the DJI
Phantom 3 UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. P art 21, Subpart H. As such, Michael Young submits that he will ensure that the DJI Phantom 3 UAS is in an airworthy condition, prior to every flight, by determining that the UAS is in compliance with the operating docum ents ( DJI Phantom 3 Instruction Ma nual), and that the aircraft is in a condition for safe flight. Michael Young also seeks an exemption from the requirements of Section 91.1 21, entitled Altimeter Settings , as the DJI Phantom 3 UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio commu nications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Michael Young ’s operation of the DJI Phantom 3 UAS within visual line of sight, at or below 400 feet AG L, will ensure a level of safety equivalent to Section 91.121. Additionally, Michael Young seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Michael Young submits that safety will not b e affected by operation of the DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 23 minutes. Battery power indicators ar e also able to show exactly how much battery power is left, as well as how much time is needed to return safely back to point of take

- off

. In accorda nce with 14 C.F.R. § 11.81, Michael Young provides the following information in support of its petition fo r exemption:6



## A. Name and Address of the Petitioner

. The name and address of the Petitioner and point of contact is: Michael Young

2021 West 73 rd Street
Tulsa Oklahoma 74132

918

- 691

- 3241 young.mike1954@gmail.com



## B. The Specific Sections of 14 C.F.R. From Which The Michael Young Seeks Exemption.

1. Michael Young Seeks Exemption from the Requirements of Section 61.113(a)
and (b).
Section 61.113, entitled Private pilot privileges and limit ations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A privat e pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

—

(1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or propert y for compensation or hire.



## 2. Michael Young Seeks Exemption From The Requirements Of Section 91.7(a).
Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.



## 3. Michael Young Seeks Exemption From The Requirements Of Section 91.121.
Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the crui sing altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—

(1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a station along the route and within 100

naut ical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.



## 4. Michael Young Seeks Exemption From The Requirements Of Section 91.151(b).
Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following:7

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.



## 5. Michael Young Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405 , entitled Maintenance required , subsection (a), states the following: Each owner or

ope rator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]



## 6. Michael Young Seeks Exemption From The Requirements Of Section 91.407(a)(1)
Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person ma y operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

—

(1) It has been approved for return to service by a person authoriz ed under § 43.7 of this chapter.



## 7. Michael Young Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).
Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the prec eding 12 calendar months, it has had

–

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.



## 8. Michael Young Seeks Exemption from the Requirements of Sections 91.417(a)
and 91.417(b).
Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the

100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, roto r, and appliance of an aircraft. The
records must include

—

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and8 (iii) The signature, and certificate num ber of the person approving the aircraft for return
to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The cur rent inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are
maintained. (v) The current status of applicable airworthiness directives (AD) and safe ty directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescri bed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The reco rds specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and
transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.



## C. The Extent Of Relief Michael Young Seeks And The Reason Michael Young
Seeks The Relief.

1. Extent of Relief Michael Young Seeks and the Reason Michael Young Seeks
Relief from Section 61.113(a) and (b).
Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC that holds either an airline transport, commercial, private, recreational, or sport pilot certifi cate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government, and who has met certain flight

- hour and c urrency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Michael Youn g submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC i s able to safely operate the DJI Phantom 3 UAS in a manner consistent with the operations specifications as described in this9

exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehic les and structures. Further, Mic hael Young submits that all flights of the DJI Phantom 3 UAS, conducted by the PIC pursuant to the grant of this Petition will not carry passengers or property for compensation or hire.



## 2. Extent of Relief Michael Young Seeks and the Reason Michael Young Seeks
Relief f rom Section 91.7(a).
Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to t he extent required to
allow Michael Young to determin e that the DJI Phantom 3 UAS is in airworthy condition prior to every flight by en suring that the UAS is in compliance with th e operating documents contained in the DJI
Pha ntom 3 Instruction Manual. Michael Young seeks the requested relief because the DJI Phantom 3 UAS do es not require an
airworthiness certificate in accordance with 14 C.F.R. Par t 21, Subpart H. Therefore, Michael Young will

ensur e that the DJI Phantom 3 UAS is in airworthy condition based upon its compliance with the
operat ing documents prior to every fligh t, and further, determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations below.



## 3. Extent o f Relief Michael Young Seeks and the Reason Michael Young Seeks
Relief f rom Section 91.121.

Relief from Section 91 .121, entitled Altimeter settings , may be required to allow flight operations of the DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA t o the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in fee t above ground level (AGL), Michael Young seeks the requested relief because the DJ I Phantom 3 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the

e xtent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 UAS are equipped with a barometric pressure sensor and GPS equip ment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude
information of the UA on the heads

- up display of the GCS.



## 4. Extent o f Relief Michael Young Seeks and t he Reason Michael Young Seeks Relief From Section 91.151(b).
Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery powered DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a to tal duration of 23
minutes. Michael Young seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powe red DJI Phantom 3 UAS will severely constrain the practicality of any aerial video or still p hoto flight operations that Michael Young proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJ I Phantom 3 UAS, the DJI Phanto m 3 operating documents, and Michael Young ’s proposed operati ng limitations, ensure that Michael Young will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in visual10

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a
total duration of 23 minutes.



## 5. Extent o f Relief Michael Young Seeks and t he Reason Michael Young Seeks
Relief f rom Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91. 417(a) & (b).
Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft
with an a irworthiness certificate, Michael Young requests relief from these Sections because the DJI
Phantom 3 UAS do es not require airw orthiness certificates. As set forth more fully below, the DJI Phantom 3 UAS meet the conditions of FMRA Section 333 for operation without an airworthines s certificate.



## D. The Reasons Why Granting Michael Young ’s Request Would Be in the Public Interest; That Is, How It Would Benefit the Public as a Whole.
Granting the present Petition will further the public interest by allowing Michael Young too safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, events and civic landscape over certain areas of the United States. Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the econom y. Notably, the benefit s of Michael Young ’s proposed operation of the DJI Phantom 3 UAS will be realized without implicating any privacy issues.



## 1. The Public Will Benefit From Decreased Congestion Of The NAS.
The DJI Phantom 3 UAS are battery powered and serve as a safe, efficie nt, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 UAS
would reduce the am ount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports c aused by arriving and departing aircraft will be reduced. The DJI Phantom 3 UAS do es not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result
in fewer aircraft that m ust be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.



## 2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3

UAS.
Conducting aerial acquisitions with the DJI P hantom 3 UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric

m otors, the DJI Phantom 3 UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while bur ning approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 UAS, while reducing the carbon footprint of aerial acquisitions, also11

eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 3 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations,
will be s ubstantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 3 UAS (weighing approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of appro ximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).



## 3. Performing Aerial Video and Photography Operations with the DJI Phantom
3 UAS Will Benefit the Economy.
In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 UAS
will allow United S tates based companies, like Michael Young , to remain competitive and contribute to growth of the U.S. ec onomy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 UAS is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phant om 3 UAS, companies such as Michael Young , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 3 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to
invest in re search and development in order to remain competitive both i n the United States and
abroad.



## 4. There Are No Privacy Issues.
Similar to the manned aerial acquisition flight operations that have been conducted for decades, Michael Young ’s proposed operation o f the DJI Phantom 3 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 UAS will be operated only in compliance with the D JI Phantom 3 Instruction Manual, which requires property owner involvement as well as local law enforcement

not ification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.



## E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal
To That Prov ided By The Rule From Which Michael Young Seeks Exemption.

1. Reasons Why The DJI Phantom 3 UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.12

In consideration of the size, w eight, speed, and limited operating area associated with the unmanned aircraft and its operation, Michael Young ’s operation of the DJI Phantom 3 UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance wi th 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Trans portation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this

Act. 15 (b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

—

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national air space system or the public or pose a threat to national security; and (2) Whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operat ion of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking t his exemption, Michael Young submits that the DJI Phantom 3 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demon strated by: (a) The characteristics of the DJI Phantom 3 UAS; (b) The pilot certification requirement; and (c) The specific operating limitations.



## a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe
Characteristics.
The DJI Phantom 3 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications of the DJI Phantom 3 UAS.
The tech nical specifications of the DJI Phantom 3 UAS are set forth by the DJI Phantom 3 User Manua l

. ii. The DJI Phantom 3 UAS Global Positioning Modes Enable The UAS To Remain Within A Defined Operational Area. The DJI Phantom 3 UAS may be operated in both manual and global positioning flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3 UAS is provided at pages
11 of the DJI Phantom 3 User Manu al

. iii. The DJI Phantom 3 UAS Are Designed For Automatic Return To Home Point Or Ho ver In The Event Of Loss Of The Control Link Or Navigation.13

When the Control Link is lost, the DJI Phantom 3 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 UAS does not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) via GPS, and will descend to the t akeoff position and shutdown. A complete description of the Failsafe
Functions of the DJI Phantom 3 UAS are set forth at pages 12 through 14 of the DJI Phantom 3 User

Manua l

. iv. The DJI Phantom 3 GCS and Its Operation. A complete description of the operation and specifications of the DJI Phantom 3 GCS and flight control software is provided at pages 23 through 29 of the DJ I Phantom 3 User Manual

.



## b. Flight Operations Of DJI Phantom 3 UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.
Michael Young will ensure only qualified pilots are allowed to act as a pilot in command (PIC) of the DJI Phantom 3 UAS. Additionally, a safety observer will assist him at all times during flight time.



## c. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific Operating Limitations.
In seeking thi s exemption, Michael You ng proposes to commercially operate DJI Phantom 3 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations. 1. Operations are limited to the DJI P hantom 3 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purpose of closed

- set motion picture and television filming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed t o determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be operated at an altitude of no more than 4 00 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than correctiv e lenses, as specified
on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The V O may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC
must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO. 7. The exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in the grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the exemption and the procedures outlined in the operating documents,14

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator

must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law e nforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon
which t he FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight crit ical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test
fli ght must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a conditio n that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufacturer’s maint enance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety
bulletins. 13. Under the grant of an exemption, a PIC mus t hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. 14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption,
includi ng evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of t raining the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted
under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditi ons (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denot ed with an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the15

exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property. 19. The PIC must abort the flight in the event of u npredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations
shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the
attached COA. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in acc ordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon re quest. 24. The UA must remain clear and give way to all manned aviation operations and activities at all

times. 25. The UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet f rom all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons;
and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property

o wner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA mu st be reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.16



## 2. Reasons Why an Exemption from the Requirements of Section 61.113 (a) And (b) Would Not Adversely Affect Safety.
Michael Young submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintainin g appropriate distances from people, vessels, vehicles and

structures. Considering Michael Young ’s proposed area of operations, and the operating limitations set forth

- above ; the parallel nature of sport pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely op erate the DJI Phantom 3 UAS, Michael Young submits that the additional manned airmanship experience of a commercially certificated pilot would not c orrelate to the air manship skills necessary for Michael Young ’s specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 1 1136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). Michael Young will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 3 UAS training and

curren cy requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specif ically, the PIC must have accumulated and logged, in a manner consiste nt with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those 25 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experie nce that was obtained in compliance with applicable regulations will ensure an equiva lent level of safety during Michael Young ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with ap plicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and l ogged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make

a nd model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA
also fin ds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also17

be conducted under the grant of exemption to accomplish t he required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate
distances in accordance with 14 C.F.R 91.119. Accordingly, Michael Young will ensure safe operations by not allow ing any PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including evasi ve and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.



## 3. Reasons Why an Exemption from the Requirements of Section 91.7(a) Would Not Adversely Affect Safety.
The equivalent level of safety establ ished by Section 91.7 (a) will be maintained bec ause prior to every flight, Michael Young will ensure that the DJI Phantom 3 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and l imitations
herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080 , 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).



## 4. Reasons Why an Exemption from the Requirements of Section 91.121
Would Not Adversely Affect Safety.
The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Phantom 3 UAS will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with The Michael Young ’s operation of the DJI Phantom 3 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equiv alent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level. The FAA has previously gra nted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 111 58, 11159, 11160, 11161).



## 5. Reasons Why an Exemption from the Requirements of Section 91.151(b) Would Not Adversely Affect Safety.
A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a resu lt of (1) The technical specifications of the DJI Phantom 3 UAS; (2) The limitations on the proposed flight operations; (3) The location of the proposed flig ht operations. Accordingly, Michael Young will ensure that it will safely operate the battery p owered DJI Phantom 3 UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 23

minutes.18

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 UAS provide s audible and visual warnings to the P IC at the GCS when the UAS experiences low battery voltage, the first warni ng occurring at approximately 30 % remaining battery

pow er, and again at approximately 20% remaining battery power. At the critically low battery level of
10% , the DJI Phantom 3 UAS will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are
considered. Re lief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstanc es similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).



## 6. Reaso ns Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.
In seeking this exemption, Michael Young submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a ) & (b) will be met because Michael Young will use traine d technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the DJI Phantom 3 Instru ction Manual). Furthermore, Michael Young will documen t and maintain all maintenance records for the DJI
Phantom 3 UAS. Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating documents, Michael Young will maintain the equivalent level of safety established by Sections 91.405(a), 91.409( a)(1), an d 91.409(a)(2). Likewise, the exemption sought will not adversely affect safety because Michael Young will use trained

tec hnicians to perform alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 3 UAS will be performed by trained technicians. Maintenance will be documented and m aintained utilizing the maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not advers ely affected when the technical characteristics and operating limitatio ns of the UAS are considered.
In consideration of Michael Young ’s proposed operating limitations, the operating documents, and the technical aspect s of the DJI Phantom 3 UAS, Michael Y oung submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, i n all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).19



## 7. The FAA May Prescribe Any Other Condit ions For Safe Operation.
In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 e ntitled Special Conditions, Michael Young requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R.

P art 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to nation al security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the

NAS. Likewise, the Administrator may prescri be special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 3 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of th e aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller bec ause of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F. R. § 21.16, the FAA may prescribe spe cial
conditions for Michael Young ’s intended operation of the DJI Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that
established b y 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 25 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

• 

## A Summary That Can Be Published in the Federal Register, stating: The Rules

From W hich Michael Young Seeks Exemption:
Michael Young seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).



## A Brief Description Of The Nature Of The Exemption Michael Young Seeks:
This exemption will permit Michael Young to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the
United States.20



## • A ny Additional Information, Views, Or Ar guments Available to Support Michael Young ’s Request.
This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if c ertain UAS may operate safely in the NAS. As such, Michael Young ’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering w hether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification.
As discussed in det ail above, Michael Yo ung will operate the DJI Phantom 3 UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.



## CONCLUSION
As set forth herein, Michael Young seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the inte rests of the public, by allowing Michael Young to safely, efficiently, and economically operate the DJI Phantom 3 UAS commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and
Reform Act of 20 12, Se ction 333, Michael Young respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91. 417(a ) & (b), and permit Michael Young to operate the DJI Phantom 3 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: December 17 , 2015

. Respectfully submitte d,

Michael Young

202 1 West 73 rd Street
Tulsa Oklahoma 74132

918

- 691

- 3242 Young.mike1954@gmail.com